HomeMy WebLinkAboutCUP 194A; Aquaculture Systems International; Conditional Use Permit (CUP) (14)1
July 5, 1990
TO : CITY MANAGER
ASSISTANT CITY MANAGER CITY ATTORNEY COMMUNITY DEVELOPMENT DIRECTOR UTI LITIES/MAINTENANCE DIRECTOR GENERAL MANAGER, CMWD
FROM: City Engineer
AGUA HEDIONDA LAGOON - PROPOSED COLIFORM STUDY
Attached is my response to the Water Quality Control Board's letter of June 11, 1990.
Please review and give me your commentsIsuggested revision by July 10,
for submittal to the Board on July 11.
LLOYPYB. HUBBS
City Engineer
LBH/pmj
Att.
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/ DRAFT r - 1
July 5, 1990
Mr. Arthur L. Coe
Acting Executive Officer
State of California
San Diego Regional Water Quality Control Board
9771 Clairemont Mesa Blvd., Suite B
San Diego, CA 92124
AGUA HEDIONDA LAGOON - PROPOSED COLIFORM SrUDY
Dear Mr. Coe:
The City is in receipt of your June 11, 1990 letter concemhg the Regional Board's
proposed action on the Agua Hedionda Lagoon Coliform Study. y LJC I'C was surprised to learn that the Board is now considering naming the City of Carlsbad as
a responsible party to participate in this study. This action would appear to be an after-
thought, in that we are excluded from the proposed study Technical Review Committee.
it is also apparent that the study design is primarily oriented towards impacts of the sewer
outfalls.
The impacts of non-point source pollution is a complex and difficult issue that is only now
being fully explored. The EPA and the State Water Quality Control Board are just
beginning to develop the data required to formulate and implement effective control
strategies. It will likely be years before cost-effective solutions to this problem will be
identified and funding sources developed to insure effective control.
The City of Carlsbad, because of its interest in preserving its lagoons, hopes to take a
leadership role in assisting to develop solutions within the framework of the proposed
Order No. 9042 NPDES pennit being reviewed-;- ,
From the perspective of Encina Water Pollution Control Facility (WPCF) and Oceanside,
we concur in the position that the impact of ocean outfalls on shell fishing operations is
an important issue that should be dealt with aggressively at the State level. It is neither
Cd 1 I w4~ 3
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s to bear the burden issues G4
proposed study
ies of limited
2075 Las Palmas Drive Carlsbad, California 92009-4859 (619) 438-1 161
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1"- J Arthur L. Coe Agua Hedionda Lagoon
July 5, 1990 Page: 2
Prior to proceeding further with the proposed study, it would be our suggestion that methods be explored to eliminate the immediate health hazards to the Seafarms West Aquaculture operation and proceed with a more global coastal study to resolve the safest means of protecting the ocean environment on a statewide and national basis.
The City of Carlsbad is currently reviewing an extension request for the Seafarms West Conditional Use Permit and will be very concerned to insure that the facility can be operated safely before such an extension would be granted.
The issue of non-point source pollution will be resolved under EPA guidelines and the Regional Board's program, as outlined in Order 90-42. This approach is the most
-
" I ., I reasonable, fair and effective one in dealing with issues far broader than the Agua -*
-J' - .- Hedionda Lagoon. -' J
Should the Board proceed to order the proposed Agua Hedionda Lagoon Study, it should either exclude the City of Carlsbad or expand the non-point source evaluation to include all contributing agencies. Any non-point source evaluation should include all sources within the study zone. This would include all agencies whose runoff is tributary to the Buena Vista Lagoon, Encinas Creek, Batiquitos Lagoon and other non-point source contributors to the Agua Hedionda Lagoon. This would involve most North County agencies which are already otherwise represented by either Oceanside or the Encina WPCF. There would seem to be little reason to single out Carlsbad or the Agua Hedionda Lagoon
to deal with a more global issue.
I would request that this letter be entered into the record of the July 16 hearing, and that the City of Carlsbad be given an opportunity to give testimony at the hearing.
Thank you for your consideration.
Cordially,
LLOYD B. HUBBS City Engineer
LBH:rz
c: City Manager Assistant City Manager
City Attorney Community Development Director
Utilities and Maintenance Director Assistant City Engineer R. J. Greaney - Carlsbad Municipal Water District R. W. Graff - Encina Water Pollution Control Facility
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SUMMARY - SEAFARMS WEST
CUP 194(A) & (B)
RePional Water Qualitv Control Board
Proposed Agua Hedionda Coliform Study submitted to City for review.
- Considering making Carlsbad, along with Encina WPCF and Oceanside,
responsible for study at estimated cost of $500,000 - $700,000.
Study apparently required due to high concentrations of coliform found in Seafarms shellfish
prior to flushing process.
1. Study to identify cause of pollution of Seafarm West products.
2. Determine necessary mitigation of potential health hazards associated with
Seafarms.
Given potential health hazards and public expense required for the study, removal of
Seafarms would eliminate the need to develop studies to id cost of shellfish
pollutants/contamination.
Engineering maintains that public funds should not be used to support private business.
Apparently State Water Quality Board, through Order 90-42, is adequately addressing non
point source pollution. Engineering wants to evaluate the cost to the public of proposed
coliform studies versus the cost to Seafarms to decontaminate the shellfish.